The defendant is charged [in count __]
with kidnapping in the first degree. The statute defining this offense reads in
pertinent part as follows:

a person is guilty of kidnapping in
the first degree when (he/she) abducts another person and (his/her) intent is to
compel a third person <insert as appropriate:>

to pay or deliver
money or property as ransom.

to engage in
particular conduct or to refrain from engaging in particular conduct.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Abducted another
personThe first element is that the
defendant abducted another person. <Insert the elements from
Kidnapping in the Second Degree, Instruction 6.5-3.>1

Element 2 - IntentThe second element is that the
defendant abducted <insert name of abducted person> with the specific
intent to compel a third person to (pay money or property as ransom / do or
refrain from doing some particular thing). A person acts "intentionally"
with respect to a result when (his/her) conscious objective is to cause such
result. <See
Intent: Specific, Instruction 2.3-1.>

You must find that the defendant
abducted <insert name of abducted person> with the specific intent to
compel some other person to (pay money or property as ransom for the person's
release / do or refrain from doing some particular thing). There is no
requirement that the defendant communicate in any way with the third person
whose (payment / action or inaction) is sought, or specifically make any demand
of that person, but merely that the defendant intends, by (his/her) act, to
compel the (payment / action or inaction).

Conclusion

In summary, the state must prove
beyond a reasonable doubt that <insert the concluding summary from the
instruction for kidnapping in the second degree>, and that (he/she) intended
to compel a third person to (pay money or property as ransom / do or refrain
from doing something).

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
kidnapping in the first degree, then you shall find the defendant guilty. On
the other hand, if you unanimously find that the state has failed to prove
beyond a reasonable doubt any of the elements, you shall then find the defendant
not guilty.
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1
Second degree kidnapping is simple abduction. See General Statutes § 53a-94.